1

EWEA response to public consultation

Preparation of a new Renewable Energy Directive for the period after 2020

February 2016

Executive summary

The European Union has played a key role in brokering a historic climate agreement in Paris and needs to

demonstrate climate leadership back home. The COP21 commitments agreed in December will require Member

States to review and update the collective EU pledges in the near future and step up efforts on renewable energy

deployment

In that context, EWEA strongly believes that the post-2020 Renewable Energy Directive should set up an ambitious

regulatory framework if the EU is to live up to its goals of fulfilling the Energy Union vision and being the world

number one in renewables.

Higher policy ambition in the post-2020 period makes clear economic sense. Under an ambitious, enabling and

robust regulatory framework, wind will deliver the following benefits to the European economy in 20301:

o €87 bn. of gross value added;

o additional €13 bn. GDP compared to business-as-usual scenario;

o 18.7% in cumulative fossil fuel savings, amounting to €11.5 bn.;

o 36.3% of CO2 emissions reduction over 1990 levels, removing an extra 111.6 Mt CO2 compared to

business-as-usual scenario;

o a total of 366,000 direct and indirect jobs in the wind industry alone.

The post-2020 Renewable Energy Directive will be the key policy instrument to deliver the binding EU renewable

energy target for 2030, ensure that the EU capitalises on its first-mover advantage in wind energy, and is on track

to meet its long-term decarbonisation objectives.

The following key enablers should be covered in the Commission’s legislative proposals for the post-2020

Renewable Energy Directive, national planning and reporting obligations and market design:

1) Enshrining in legislation the Energy Union governance provisions relevant to renewables, namely:

o binding template for national energy and climate plans;

o a concrete timeline for finalising the first post-2020 national plans;

o clear safeguard measures and enforcement tools for the European Commission to oversee and

ensure target delivery.

2) Setting up a regional approach to renewable energy deployment based on:

o A regional approach to power system management;

o An EU-level financing facility granting support to projects of regional relevance;

o A clear political commitment to convergence of national regulatory frameworks for offshore wind in

view of bringing down deployment costs.

3) Enabling the cost effective deployment of wind energy thanks to an upgraded market design:

o providing investors with a stable regulatory framework including revenue stabilisation measures and

avoiding any retroactive measures;

o maintaining priority dispatch provisions and balancing responsibility exemptions as long as market

failures are not addressed;

1 Data modelling: Pöyry, Cambridge Econometrics

2

o increasing transparency to limit curtailment and guarantee that renewable production is not

constrained to the benefit of thermal power production;

o using Capacity Remuneration Mechanisms (CRMs) as a last resort option and only after standardized

system adequacy analysis;

o improving the cooperation between system operators and further grid reinforcements both at

transmission and distribution levels;

o increasing liquidity and cross-border trading in all market time frames to re-establish adequate price

signals;

o maximising trading opportunities for wind power generators by ensuring their full participation in

intraday and balancing markets (e.g. short bidding periods, separate procurement energy/capacity);

o establishing a proper market for ancillary or grid support services that would provide additional

revenue streams to wind power producers.

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Consultation questions

1. To what extent has the RED been successful in helping to achieve the EU energy and climate change

objectives?

Very successful Successful Not very successful Not successful No opinion

x

Comments: To what extent did implementation measures for the RED as well as external factors (technological

development, financial crisis, security of supply concerns and related market interventions) affect the

effectiveness and efficiency of achieving the objectives? Please identify and ideally also quantify the direct and

indirect costs and benefits such as macroeconomic effects, competitiveness effects, innovation, cost and cost

reductions, environmental and health effects of the RED.

The clearly defined European regulatory framework agreed in co-decision, with binding national targets for

renewables and concrete planning and reporting obligations, was decisive in fostering national policies and

attracting private investment in renewable energy assets. Enabling measures such as priority access to the grid,

priority dispatch and national support mechanisms for renewables underpinned this development.

Driven by supportive frameworks, wind power is today a mainstream industry covering 11% of the EU’s electricity

demand and providing a cost-effective solution to climate and energy challenges. The scalability of wind energy

(141 GW by end 2015), underpinned by regulatory continuity in major markets (e.g. Germany), has incentivised

technological innovation and cost reductions. In terms of LCOE, onshore wind is the cheapest power generation

technology in Europe 2.

Wind energy provides substantial net benefits to the European economy. In 2014 alone, the sector generated an

annual turnover of more than €67 bn3 and avoided 190 Mt CO2 emissions entailing CO2 cost savings of €2.8 bn.

to €7.6 bn4. The industry currently represents more than 260,000 jobs.

While clearly successful, the RED has lacked adequate tools to follow through the EU renewable energy objectives.

Since 2011, several Member States have questioned the appropriateness of renewable support mechanisms and

have proceeded with abrupt cuts and retroactive changes thus undermining the viability of existing projects.

The European Commission’s inability to safeguard the rule of law principle underpinning investor protection has

demonstrated the limits of the current regulatory framework. Leading European wind markets (e.g. Spain) stalled

whilst some Member States (e.g. UK) are at risk of not meeting their 2020 obligations. The lack of visibility on

penalties for non-fulfilment of the 2020 national targets adds to investors’ uncertainty.

In a letter addressed to the European renewables industry, Mr Jyrki Katainen, Vice-President of the European

Commission, highlights that: “[…] Under EU law as it stands today, the Commission cannot go further than that

[provide guidance to Member States]. The [RED] gives Member States discretion to decide on the design and the

level of support for renewables. EU State aid rules allow Member States to grant aid, but do not impose any

obligation to do so”5.

Stable frameworks remain crucial for sustaining investment flows and cost reductions. EWEA calls on the

European Commission to propose ambitious post-2020 regulatory framework with the appropriate safeguard

2 BNEF, Levelised Cost of Electricity Update – H2 2015. In Germany, onshore costs $80/MWh compared to gas at $118/MWh and coal at

$106/MWh. In the UK, onshore costs $85/MWh compared to $115 for CCGT and $115 for coal-fired installations. 3 Pöyry analysis, 2015 4 Pöyry analysis, 2015 5 Response from Mr. Jyrki Katainen, Vice-President of the European Commission, to the European renewable energy industry letter on investor

protection, 18 November 2015, Ref. Ares(2015)5211058

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measures, enforcement tools and investment protection mechanisms to secure the fulfilment of the 2030

renewables target.

2. How should stability, transparency and predictability for investors be ensured with a view to achieving

at least 27% renewable energy target at EU level? Please indicate the importance of the following

elements:

Very

important

Important Not very

important

Not important No opinion

Forward looking strategic

planning of RES

development is required by

EU legislation

x

Best practice is derived from

the implementation of the

existing Renewable Energy

Directive

x

Regional consultations on

renewable energy policy and

measures are required

x

Member States consult and

adopt renewable energy

strategies that serve as the

agreed reference for

national renewable energy

policies and projects

x

The Commission provides

guidance on national

renewable energy strategies

x

Box: Any other view of ideas? Please specify. What are the lessons from the RED (mandatory national targets,

national plans, progress reports, etc.)?

The mid-term evaluation of the RED6 clearly concluded that the RED owes its effectiveness to binding national

targets, national renewable energy action plans (NREAPs) and biennial reporting. In the absence of 2030 national

targets, EWEA believes that a robust governance system is key to providing investors certainty for the post-2020

period and ensuring that investments remain within the EU.

Wind investors are currently faced with a regulatory vacuum and lack of visibility over markets growth due to the

lack of national renewable energy plans for the post-2020 period in 22 out of 28 Member States. This prevents

timely investment decisions and endangers the bankability of renewable energy projects.

Guarantees should therefore be in place to ensure well-defined national commitments to renewable energy

deployment beyond 2020 and efficient oversight of the European Commission over target delivery. In a letter to

the sustainable energy sector, Vice-President Šefčovič and Commissioner Cañete shared our views whereby the

6 Mid-term evaluation of the Renewable Energy Directive, April 2015

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“governance framework for the Energy Union has to be credible, strong, resilient and robust, building on existing

planning and reporting mechanisms and rooted in the EU rule of law” 7.

EWEA has identified three priorities to address this.

Planning

The European Commission should set benchmarks for each Member State, which aggregated, amount to the

27%. Based on the benchmarks, Member States should define the renewable energy component of their national

climate and energy plans, building upon the 2020 national target. These plans should be finalised well ahead of

2020 to ensure a seamless transition into the post-2020 period. This is particularly important for offshore wind

energy projects which typically have a lead time of five years.

National plans should be based on a uniform, binding template to ensure coherence and comparability between

Member States contributions to the 27% target. The renewable energy components of national plans’ template

should be duly enshrined in horizontal legislation and referenced in the new Renewable Energy Directive.

Member States that go beyond the Commission’s proposed growth path should receive additional incentives in

proportion to their ambition such as increased and facilitated access to structural funds, NER400 funding and

financing from the European Investment Bank for renewable energy projects.

Monitoring

The European Commission should have a reinforced oversight over Member States’ progress and should be able

to intervene in case of counter-productive measures (e.g. negative impact on existing/future investments) to

national regulatory framework. The new Directive should clearly outline the circumstances requiring intervention

and the legal tools at the Commission’s disposal.

As under the European Semester, the Commission should make official policy recommendations on national

renewable energy policies.

Legal basis

The governance system needs to be agreed in co-decision ensuring equal involvement from Member States and

the European Parliament to ensure democratic legitimacy. The European Commission should table its governance

provisions relative to renewable energy in horizontal legislation and reference them in the new Renewable Energy

Directive.

3. Please rate the importance of the following elements being included in Member States’ national energy

and climate plans with respect to renewable energy in ensuring that the plans contribute to reaching

the objective of at least 27% in 2030.

Very

important

Important Not very

important

Not

important

No opinion

Long term priorities and visions for

decarbonisation and renewable

energy up to 2050

x

In relation to national/regional

natural resources, specific

technology relevant trajectories for

renewable energy up to 2030

x

7 Response to the clean energy industry, 15 September 2015, ARES(2015)3807163

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Overview of policies and measures

in place and planned new ones

x

Overview of renewable energy

trajectories and policies to 2050 to

ensure that 2030 policies lie on the

path to 2050 objectives

x

Qualitative analysis x

Trajectories for electricity demand

including both installed capacity

(GW) and produced energy (TWh)

x

Measures to be taken for

increasing the flexibility of the

energy system with regard to

renewable energy production

x

Plans for achieving electricity

market coupling and integration,

regional measures for balancing

and reserves and how system

adequacy is calculated in the

context of renewable energy.

x

Energy and climate planning is crucial to mitigate policy uncertainty and enable the cost-effective deployment of

renewables by 2030. In November 2015, the EU Energy ministers recalled that long-term planning “will enhance

the stability and predictability of the investment climate”8.

Plans should be developed well in advance of 2020 to inform wind energy investors of future market growth

potential and ensure a smooth transition towards the 2030 period. Finalising the first national plans by the end of

2019 is too late for investors to prepare the post-2020 investment cycle and to ensure that the projects necessary

to deliver the 2030 target will be executed in time.

To be reliable, national plans should be developed based on a binding, standardised template decided in co-

decision and rooted in the EU rule of law. This could be done in horizontal legislation and should be duly

referenced in the new Renewable Energy Directive.

National plans should also incorporate the revision of relevant sectorial legislation (e.g. Renewable Energy

Directive, Energy Efficiency Directive) in order to allow Member States to develop coherent and stable policy

frameworks and deliver their 2030 renewable energy contributions.

A lesson learned from the current regulatory regime is that national plans became outdated and progress reports

failed to address key regulatory challenges to the deployment of renewables. The European Commission should

therefore have a reinforced oversight over Member States’ progress and the ability to make country-specific

recommendations at every biennial reporting cycle in order to address challenges in meeting national objectives.

National plans should be updated once, in 2024, in order to take stock of changing circumstances and to ensure

that the EU is on track to reach the target of at least 27%. If that is not the case, such an early indication will allow

for the Commission to undertake the necessary corrective measures.

National plans should include:

8 Energy Council, Conclusions on the governance system of the Energy Union, 26 November 2015

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Targets and objectives for 2030 and 2050: to ensure that Member States are in line with the EU’s long-

term decarbonisation objectives and map market growth potentials;

Sectoral targets and trajectories: Member States renewable energy commitments should be broken down

in sectoral targets and trajectories (electricity, heating and cooling, transport). For maturing technologies,

such as offshore wind, the 2030 national commitments need to indicate specific deployment volumes

planned, including in cooperation with neighbouring States, and deliver cost reductions through

scalability;

Indicative trajectories and intermediate targets: to ensure a linear progress towards the 27% renewable

target and to give an early indication of potential deviation;

National measures for the deployment of renewables including support mechanisms, infrastructure

development and streamlining of administrative procedures;

Indicative measures adopted by Member States in renewable energy-related areas (e.g. taxation,

environmental requirements, etc.) to ensure coherence among different policy streams.

The general elements and concrete details of national plans should allow Member States to aim higher that the

27% renewable energy target by 2030 and demonstrate their commitment to delivering on the long-term EU

decarbonisation objectives.

4. What should be the geographical scope of support schemes, if and when needed, in order to drive the

achievement of the 2030 target in a cost-effective way?

Harmonised EU-wide level support schemes

Regional level support schemes (group of Member States with joint support scheme)

National support schemes fully or partially open to renewable energy producers in other MS

X Gradual alignment of national support schemes through common EU rules

National level support schemes that are only open to national renewable energy producers.

The objective of the wind industry is to be competitive in a liberalised electricity market characterised by a level

playing field. While market integration and liberalisation progress, national wind energy support mechanisms

should be designed to deliver more convergence while taking into account varying renewable potentials, grid

access costs, administrative costs, cost of capital and national fiscal frameworks. With increasing wind energy

penetration levels, support mechanisms should also encourage greater market responsiveness resulting in

gradually decreasing support levels.

Convergence will strongly depend on the elimination of structural barriers preventing the completion of the

internal energy market (e.g. regulated prices, subsidies for conventional power generators, etc.) and should also

be adapted to renewable energy technology maturity.

Even a fully-revamped power market framework may not be sufficient to guarantee an adequate return on

investments especially for low marginal cost and CAPEX-intensive power generation technologies such as wind

energy. Revenue stabilisation mechanisms that help finance new power generation capacity should consequently

be developed9.

9 EWEA, Market design position paper and Response to public consultation on a new energy market design, 2015

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Onshore wind

In the post-2020 period, onshore wind incentives should come in the form of market-compatible instruments such

as premiums. The level of the premium would vary between Member States to reflect the specific development

costs in the different countries (cost of capital, grid connection costs, administrative costs, etc.).

The premium level may result from a competitive bidding process provided that it is developed in consultation with

the industry. The European Commission should assess the success of competitive bidding as a support

mechanism allocation tool prior to setting up the post-2020 State aid guidelines.

Where competitive bidding does not provide an efficient and cost-effective tool for support allocation, the

Commission should develop a methodology for feed-in premiums to be used in all Member States. This method

will identify the different cost components to calculate a premium level and suggest a common duration (in years

or full load hours) of the support mechanism. The methodology would be based on the approach presented in the

Commission November 2013 guidance on support mechanisms, and enable market incentives in the different

countries to be compared.

Offshore wind

EWEA favours the development of a voluntary framework to support offshore wind in Europe to be agreed through

a bottom-up process in the context of existing cooperation structures (e.g. NSCOGI / BEMIP) involving government,

industry and TSO representatives.

First, relevant Member States would agree on a framework for environmental and technical requirements and a

development plan for infrastructure to enable offshore wind development. This would help create the conditions

for determining a common incentive system, possibly leading to joint voluntary targets for offshore wind, adding

on existing national commitments. Member States may facilitate the deployment of offshore wind volumes by

coordinating the timing and size of offshore wind auctions and identifying common projects that could be up

scaled or developed regionally so as to maximise benefits for consumers and the industry.

5. If EU-level harmonised/regional support schemes or other types of financial support to renewable

energy projects would be introduced:

- What hinders the introduction at the EU wide/or regional scale?

- How could such mechanism be activated and implemented?

- What would be their scope (what types of projects / technologies / support mechanisms could be

covered?

- Who would finance them?

- How could the costs of such measures be shared in a fair and equitable way?

Convergence versus harmonisation

EWEA considers that bottom-up convergence of support mechanisms, as spelled out in question 4, is more

appropriate to allow for the cost-effective deployment of renewables in the EU. Convergence implies the alignment

of certain support mechanism elements across several Member States and could be explored in the framework of

cooperation mechanisms.

Partial opening of national support mechanisms could be done on a voluntary basis and through bilateral

agreements to optimise resource use and ensure a cost-efficient transition of the energy system. However, the

impact on the social acceptance of national renewable energy policies should be carefully considered.

An EU-level support mechanism could be envisaged only as an instrument of last resort to fill a potential gap

towards the EU-wide renewables target.

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Regional approach

EWEA considers that regional renewable energy targets should not be imposed by the European Commission. They

would only replicate the difficulty of breaking down an overarching target into concrete commitments (as for the

EU-wide target), and assigning accountability for non-delivery. Top-down, binding regional targets would add a

second layer of complexity for investors who are already struggling with an unclear 2030 governance mechanism.

Instead, a regional approach to wind deployment should result from voluntary cooperation by Member States with

the European Commission acting as a facilitator. A regional approach to planning and operating the power system

and market will underpin renewable energy support mechanism convergence. Regional impact assessments,

system adequacy analyses and cost-benefit analyses should be developed in parallel in order to provide an

equitable and transparent evolution.

Furthermore, financial support to renewable projects of regional relevance could be granted through a newly

established EU-level financing facility. A guarantee fund, similar to the European Fund for Strategic Investments

(EFSI), targeting renewable energy projects could help unlock investments in green assets and facilitate the

delivery of the collective 27% renewable energy target. Whereas the main capital would be provided by the

European Investment Bank (EIB), regional cooperation could be further strengthened through financial incentives

and increased cooperation with other regional development and/or green banks. The Connecting Europe Facility

could be the vehicle for this new instrument.

Offshore wind is well suited to implement the regional approach promoted by the European Commission. In this

context, regulatory convergence should be prioritised as a means to support the cost-effective deployment of

offshore wind. Different national standards (e.g. health & safety, operation and maintenance, environment)

needlessly drive up costs and should be addressed as part of a regional dialogue. The launch of a shared testing

and verification facility for offshore wind would also boost efforts towards cost reduction.

The North Seas Offshore Grid and the Baltic Energy Market Interconnection Plan (BEMIP) should also feature

among the long term priorities for enhanced regional cooperation as part of the Energy Union.

6. The current Renewable Energy Directive gives Member States the possibility to enter into various

cooperation mechanisms (statistical transfer, joint projects and/or joint support schemes). Please

expand on the possible new legislative and non-legislative measures that could be introduced to foster

the development of cooperation mechanism in the period beyond 2020.

EWEA considers that cooperation mechanisms have a role to play in meeting the 2030 targets cost-effectively.

Given that the 2030 renewable energy target is binding at the EU level, cooperation mechanisms should be

further exploited in order to facilitate the creation of cross-border markets for renewables.

The Commission should also create additional incentives that make cooperation economically attractive. For

instance, EWEA considers that the European Commission should set benchmarks for each Member States as part

of the Energy Union governance mechanism. Aggregated, the benchmarks would amount to 27% and serve as a

basis for Member States to define the renewable energy component of their national climate and energy plans.

Member States that go beyond the Commission’s proposed growth path, including through cooperation

mechanisms, should receive incentives in proportion to their ambition. For example, ambitious Member States

should benefit from increased and facilitated access to structural funds earmarked for renewable energy and

related projects. The ambitious Member States would also benefit from facilitated access to funds from the

NER400 programme for renewable energy projects.

Furthermore, the success of cooperation mechanisms beyond 2020 will largely depend on the completion of the

internal energy market. The market design reform should prioritise the deployment of intraday and balancing

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markets to foster liquidity and cross-border integration in all timeframes. Cross-border trading of renewable energy

will also require enhancing grid infrastructure at national, regional and EU level.

7. The use of cooperation mechanisms has been limited to date. Which of the below factors do you

consider important in explaining the limited recourse by Member State to cooperation mechanisms so

far?

Very

important

Important Not very

important

Not

important

No opinion

Unclear legal provisions x

Administrative complexities x

Lack of cost-effectiveness / uncertain

benefit for individual Member State

x

Government driven process, not

market driven

x

Member States reluctant to see their

taxpayers / consumers’ money used

for investments outside their country

x

The reasons behind the limited use of cooperation mechanisms under the 2020 framework have been well

documented in literature. The lack of clarity from the European Commission as to the penalties that would be

imposed on the Member States failing to meet their 2020 target has prevented them from making a proper cost-

benefit analysis justifying cooperation mechanisms. Other elements include:

Political barriers

Under the current framework, cooperation mechanisms are considered as a measure of last resort to achieve

national targets. Due to the difficulty of predicting whether national targets will be reached and whether there

would be a surplus/deficit in national renewable energy shares, Member States have been reluctant to resort to

flexibility options. It has also proven difficult to quantify the exact costs (e.g. grid infrastructure upgrade) and

benefits (e.g. employment) of cooperation mechanisms, and their distribution among host and buying Member

State. Public opposition to exploiting the best domestic renewable energy sources (for the host country) or

financing renewables deployment (for the buying country) have also been difficult to address by public authorities.

Moreover, cooperation mechanisms are set up between Member States without consultation with the industry

thus creating little incentive for developers to proceed with relevant projects.

Technical barriers

A major technical barrier is the uncertainty about the specific design of cooperation mechanisms. Agreeing on a

common support mechanism when countries have divergent renewable energy potentials and technology

preferences, different power market regulation and design have represented a challenge for the creation of joint

support mechanisms. The lack of sufficient infrastructure capacity has been a key obstacle in the development of

joint projects requiring physical transfer of electricity between the host and the buying country. The insufficiently

interconnected power market was a key obstacle in the development of joint support schemes. Further market

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and grid integration is necessary to allow for physical cross-border trading of renewable energy and incentivise the

use of cooperation mechanisms.

Legal barriers

A major concern is the unclarity of how State aid guidelines provisions will apply to cooperation mechanisms. The

administrative set-up and the distribution of responsibilities between the host and buying state are also believed

to create an additional burden to national administrations and further disincentivise cooperation.

8. How could renewable electricity producers be fully or partially eligible for support in another Member

State? Which elements would you include in a possible concrete framework for cross-border

participation in support schemes? Any other consideration? Please explain.

EWEA supports cooperation between Member States, including the opening of national support mechanisms to

non-national projects, on condition that the system is voluntary for the Member States and there is a physical flow

of the electricity to the Member State providing the support.

The Partial opening EU Member States’ support mechanisms could be promoted as a tool of optimising resource

use. The impact on the public acceptance of national renewable energy policies should be carefully considered.

The eligibility of renewable energy projects for support in another Member State should be based on a set of

predefined conditions including:

- the off-taking Member State should accept the permitting, and grid-connection rules of the host

country;

- the off-taking Member State remuneration scheme should apply.

The completion of the internal energy market is a necessary prerequisite for the cross-border participation in

support schemes. Cross-border trading of renewable energy will require enhancing grid infrastructure at national,

regional and EU level and the removal of existing bottlenecks as well as the deployment of intraday and balancing

markets to foster liquidity and cross-border integration in all timeframes10.

9. Please assess what kind of complementary EU measures would be most important to ensure that the

EU and its Member States collectively achieve the binding at least 27% EU renewable energy target by

2030.

Very

important Important

Not very

important

Not

important

No

opinion

EU-level incentives such as EU-level

or regional auctioning of renewable

energy capacities

x

EU-level requirements on market

players to include a certain share of

renewables in production, supply or

consumption

x

EU-level financial support (e.g. a

guarantee fund in support of x

10 EWEA, Market design position paper and Response to public consultation on a new energy market design, 2015

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renewable projects)

EU-level support to research,

innovation and industrialisation of

novel renewable energy

technologies

x

Enhanced EU level regulatory

measures x

EWEA believes that a robust, reliable and transparent governance system with a reinforced oversight of the

European Commission over Member States’ progress towards the 27% target is key to providing investors

certainty for the post-2020 period and ensuring that investments will remain within the EU.

Safeguard measures (gap-avoiders)

The new Renewable Energy Directive should provide incentives for Member States to raise renewable energy

ambition from the onset and avoid a gap between national contributions and the 27% EU-wide target. Gap-

avoiding measures may include:

1. Additional incentives for Member States that go beyond the Commission’s benchmarks such as increased

and facilitated access to structural funds, NER400 funding and financing from the European Investment

Bank for renewable energy projects;

2. Financial support from existing funds (e.g. ETS Modernisation Fund) to be only granted on the condition

that Member States comply with their RES pledges and thus give their fair share in achieving the common

27% target.

The European Commission should define, as part of the post-2020 Renewables Directive, a course of action in

case national contributions do not add up to the EU-wide target. Complementary instruments (gap-fillers) should

be deployed as a measure of last resort but need to be clearly set out in the new Renewable Energy Directive and

actionable as of 2020. The Directive should also outline the concrete conditions under which such measures will

be activated.

Trigger mechanisms

If the national contributions were not to add up to the EU wide objective, the Commission should engage with

Member States, in particular those with contributions below the level originally suggested, and make proposals to

ensure the EU-wide renewable energy target is met:

1. The Commission should actively broker cooperation and provide guidance on the use of cooperation

mechanisms in the post-2020 period;

2. If the Member State commitments to cooperation mechanisms are insufficient to cover the gap between

the sum of the national contributions and the EU-wide target, the European Commission should be able to

activate an EU-level gap-filler instrument to meet the target.

The gap-filler could take the form of EU fund supporting renewable energy projects whereby the support would be

distributed through a well-designed EU-wide tender system. As additional incentive, the awarded projects could

also count on preferential terms for loans (e.g. grace period at the beginning of the loan, longer maturity).

Financing the gap-filler instrument

1. Member States contributions

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All Member States should contribute to this instrument taking GDP into consideration. In order to incentivise early-

movers, a smaller financial contribution should be imposed on those Member States who have enacted ambitious

renewables frameworks at the national level.

2. Contributions from under-achievers

The Member States with national contributions below the benchmarks would be required to make an extra

contribution to the EU fund promoting the development of renewable energy projects.

10. The Energy Union Framework Strategy sets the ambition of making the European Union the global

“number one in renewables”. What legislative and non-legislative measures could be introduced to

make/strengthen the EU as the number one in renewables? Has the RED been effective and efficient

in improving renewable energy industrial development and EU competitiveness in this sector?

Through well-defined mechanisms for renewable energy deployment, the current Directive cemented the EU’s

position as a global industrial hub for onshore and offshore wind energy. The new Renewable Energy Directive

should provide a similar level of market certainty to capitalise on the EU’s early-mover advantage and maintain its

leadership position.

While the EU still leads in innovation, other parts of the world are rapidly catching up in wind energy deployment.

Within the UNFCCC framework, 70 countries outlined wind in their INDCs as a cost-effective decarbonisation tool.

In the post-2020 period, ambition from policy makers will still be required to drive the sector forward in the face of

increasing international competition. To date only six EU Member States have operational policies supporting the

deployment of renewables for the post-2020 period.

Maintaining global leadership in wind energy requires a strong home market with clear growth perspectives. A

robust governance system for the 2030 target is key to providing long-term predictability to investors and

maintaining a vibrant home market. The governance mechanism needs to be set in legislation, provide clarity over

Member States concrete contributions to the 27%, outline safeguard measures and provide enforcement tools for

the European Commission to oversee and ensure target delivery.

The EU also needs to show leadership by upgrading its energy system to accommodate large shares of

renewables. Efforts in making the internal energy market fit for renewables should prioritise the deployment of

intraday and balancing markets to foster liquidity and cross-border integration in all timeframes. Completing the

internal energy market will also require grid reinforcements at national, regional, EU level as well as institutional

strengthening of ACER and ENTSO-E.

The EU should prioritise the electrification of heat and transport sectors in order to increase power demand and

signal new investments in zero-carbon technologies such as wind energy. Moreover, EU policies in the areas of

taxation, finance, environmental legislation, etc. should all be aligned with the long-term decarbonisation

objectives of the Union and act as enablers for low-carbon technologies deployment.

The European Commission should maintain a clear focus on research and innovation for wind energy to assert the

EU as a pioneer in ground-breaking wind technologies. R&I measures and EU financial instruments should be

directed towards first-of-a-kind projects and specifically close-to-market demonstration projects.

Increased communication, coordination and collaboration between stakeholders should be ensured within the

framework of the SET-Plan Steering Group and the European Technology and Innovations Platform on Wind

energy. Test and demonstration facilities for innovative technologies need to be made available for renewable

technology producers.

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Empowering consumers

11. How would you rate the importance of the following barriers for consumers to produce and self-

consume their own renewable energy?

Very

important

Important Not very

important

Not

important

No

opinion

Self-consumption or storage of

renewable electricity produced

onsite is forbidden

Surplus electricity that is not self-

consumed onsite cannot be sold to

the grid

Surplus electricity that is not self-

consumed onsite is not valued

fairly

Appliances or enabler for thermal

and electrical storage onsite are

too expensive

Complex and/or lengthy

administrative procedures,

particularly penalising small self-

consumption systems

Lack of smart grids and smart

metering systems at the

consumer's premises

The design of local network tariffs

The design of electricity tariffs

12. In general, do you think that renewable energy potential at local level is

- Highly under-exploited

- Under-exploited

- Efficiently/fully exploited

- Over exploited

13. How would you rate the importance of the following barriers that may be specifically hampering the

further deployment of renewable energy projects at the local level:

Very

important

Important Not very

important

Not

important

No opinion

Lack of support from Member State

authorities

x

Lack of administrative capacity and/or

expertise/ knowledge/information at the

x

15

local level

Lack of energy strategy and planning at

local level

x

Lack of eligible land for projects and private

property conflicts

x

Difficulties in clustering projects to reach a

critical mass at local level

x

Lack of targeted financial resources

(including support schemes)

x

Negative public perception x

European mechanisms should be aimed at increasing technical skills and knowledge from Member State

governments in dealing with the design, planning and administration of renewable energy projects at local level.

For example, mature markets for wind energy such as Denmark and Germany have set up agencies and

regulations at local level than can be transferable to less developed markets. Incentives for pioneer countries

could be set in place to encourage the transfer of skills and best practices in planning, consenting and permitting

onshore and offshore wind energy projects.

The setup of regional data sharing platforms for environmental impact assessments, wind resources, marine and

subsea bed conditions as well as fauna migration routes are needed for facilitating the deployment of wind

energy.

Finally mutual recognition of environmental, health and safety standards and cross-border cooperation between

local authorities for reducing red tape and regulatory barriers should be part of regional cooperation mechanisms.

14. Please rate the appropriateness of stronger EU rules in the following areas to remove barriers that may

be specifically hampering the further deployment of renewable energy projects at the local level:

Very

appropriate

Appropriate Not very

appropriate

Not

appropriate

No

opinion

Promoting the integration of

renewable energy in local

infrastructure and public services

x

Supporting local authorities in

preparing strategies and plans for

the promotion of renewable

energy

x

Facilitating cooperation between

relevant actors at the local or

municipal level

x

Facilitating access to targeted

financing

x

EU-wide right to generate, self-

consume and store renewable

electricity

x

16

Measures to ensure that surplus

self-generated electricity is fairly

valued

x

Harmonized principles for

network tariffs that promote

consumers flexibility and

minimise system costs

x

Generators are exposed to the following network charges applying to both transmission and distribution tariffs:

One-off costs: grid connection charges (shallow or deep);

Variable costs: injection charges (in €/MW or €/MWh) and system service use charges (losses, ancillary

services, administrative or metering fees).

Each Member State has its own methodology to design network tariffs, because the costs are dependent on

network type, system size, voltage level etc. EWEA believes that such differences could hamper the development

of wind energy in areas with high resources and that they tend to distort investment signals.

In some cases, injection charges can be prohibitive, representing an important market entry barriers to new wind

energy developers. If the market is to make the most cost-effective use of renewable resources across Europe,

charging regimes at transmission level should converge11. Such harmonisation could be sought through an EC

Guideline as provided for in the Third Energy Package. In the long term, they should be progressively phased out

and network costs should be socialised.

Locational pricing is sometimes implemented to incentivise investments in less congested areas, leading to a

more efficient network development. However, such charges should be apportioned fairly given the fact that wind

energy generation, like many other energy sources, depends mostly on the quality of the resource rather than the

proximity to load centres. New generation built close to demand centres could be less cost effective on a life-cycle

basis, since the reduced energy yield in a suboptimal location can outweigh any anticipated savings in grid

reinforcement costs. The use of locational signals should be avoided for injection charges in order to have a level

playing field for all generators.

Finally, while connection charges are always applied to generators, EWEA believes that new generating capacity

should not be charged the full cost of overall grid reinforcements emerging from their marginal contribution to the

power system in comparison to older, exempted, power plants. Therefore, shallow grid connection charging

regimes, both at transmission and distribution level, should be best practice across Europe, notably in Member

States where power-based G charges and disproportionate locational signals apply in parallel.

15. Should the current system for providing consumers with information on the sources of electricity that they

consume be further developed and improved?

[If not, why? If yes, how? Should the current Guarantees of Origin (GO) system be made the mandatory form of

information disclosure to consumers? Should other information, such as e.g. CO2 emissions be included? Should it

be extended to the whole energy system and include also non-renewable sources? Other ideas? To what extent

has the current GO system been successful in providing consumers with information on the sources of electricity

that they consume? Max 500 words]

11 13 countries apply G-charges, out of which 3 apply capacity-based G charges. These tend to discriminate power plants with lower running

hours. Also, regulation 838/2010 establishes as a general rule that G charges must be between 0-0.5€/MWh, but allows higher value for

several countries without justification. Finally, variable charges related to ancillary services and losses are applied in 4 countries.

17

Guarantees of origin (GO) and information disclosure can be an important factor to drive demand from a market

perspective. Raising consumer awareness on the source of their electricity enables them to make informed

choices and potentially request that suppliers provide renewables-based energy. The GO scheme in Europe should

be further deployed, continuing to distinguish the specific origin of the source. It should be stressed however that

demand for GOs is very unlikely to yield sufficient revenue to support renewable energy deployment.

The influx of low-cost hydro-based GOs from Norway should be addressed, as this has contributed to driving down

significantly the value of GOs. It has also led to fragmentation of the various GO products and resulted in low

liquidity markets. Furthermore a fragmented GO market opens the door to misleading communication on power

procured from undisclosed producers (e.g. coal or nuclear power).

The GO should not only include renewable electricity, but be extended to all sources of energy. Consumers should

be properly informed on whether they are purchasing power from nuclear, coal, gas or large hydro energy or

renewables.

Decarbonising the heating and cooling sector

16. Please rate the importance of the following barriers in hampering the deployment of renewable H&C in the

EU:

Very important Important Not very

important

Not

important

No opinion

Real or perceived incoherence in

existing EU policies

x

Lack of administrative capacity

and/or

expertise/knowledge/information

at national level

x

Lack of energy strategy and

planning at the national and local

level

x

Lack of physical space to develop

renewable H&C solutions

x

Lack of requirements in building

codes and other national or local

legislation and regulation to

increase the share of energy

from renewable sources in the

building sector

x

Heating and cooling equipment

installers lack sufficient

knowledge or information to offer

renewable energy alternatives

when asked to replace fossil fuel

heating and cooling equipment

x

Lack of targeted financial

resources and financing

x

18

instruments

Lack of definition and recognition

of renewable cooling

x

Lack of electricity market design

supporting demand response,

decentralised energy and self-

consumption and thermal

storage in buildings and district

systems

x

Lack of mapping tools to identify

the resources potential at

regional scale with local

renewable energy

x

Lack of tools and information to

compare the lifecycle costs of the

various alternative heating and

cooling alternatives

x

Negative public perception x

The EU should prioritise the electrification of the heating and cooling sector in order to increase power demand

and signal new investments in zero-carbon technologies such as wind energy. A comprehensive and coherent

heating and cooling strategy should be set in place, including:

o Full implementation of the current renewable energy and energy efficiency legislation;

o Fostering synergies between the heating and cooling sector, circular economy package and energy

efficiency and ensuring coherence between sectorial legislation;

o Fostering stricter building standards and setting up 2030 and 2050 renovation targets for the building

sector in line with the revision of the Energy Efficiency Directive;

o Strengthening existing provision in favour of on-site/nearby renewable generation in the Energy

Performance of Buildings Directive;

o Setting in place a market design that incentivizes consumers to make heating and cooling choices;

o Promoting R&D funding for innovative technologies.

17. Please rate the most effective means of addressing these barriers and advancing the decarbonisation of EU

heating and cooling supply:

Very

effective

Effective Not very

effective

Not

effective

No

opinion

Renewable heating and cooling obligation x

Requirement for energy suppliers and/or

distributors to inform consumers of the

costs of heating and cooling and to offer

renewable heating and cooling solutions

x

Requirement that all urban and municipal

infrastructure upgrades (energy

infrastructures, and other relevant

infrastructure, such as sewage water,

x

19

water and waste chains) make it possible

and promote the distribution and use of

renewable energy for heating and cooling

and hot water generation

Measures supporting best practices in

urban planning, heat planning, energy

master planning, and project development

x

Criteria and benchmarks for promoting

district heating and cooling taking into

consideration the local and regional

conditions

x

Nearly zero-energy building (NZEB)

standards to include a mandatory

minimum use of renewable energy

x

Including systematically renewable energy

production in buildings' energy

performance certificates

x

The promotion of green public procurement

requirements for renewable heating &

cooling in public buildings

x

Heating and cooling equipment installers

should present renewable energy

alternatives when asked to replace fossil

fuel heating and cooling equipment

x

Develop best practices for enterprises,

including SMEs, to integrate renewable

heating and cooling into their supply chains

and operations

x

Requirement to consider renewable energy

alternatives in subnational, national,

regional or EU security of supply risk

preparedness plans and emergency

procedures

x

Targeted financial measures x

20

Adapting the market design and removing barriers

18. In your view, which specific evolutions of the market rules would facilitate the integration of renewables

into the market and allow for the creation of a level playing field across generation technologies? Please

indicate the importance of the following elements to facilitate renewable integration:

Very

important

Important Not very

important

Not

important

No

opinion

A fully harmonised gate closure time for

intraday throughout the EU

x

Shorter trading intervals (e.g. 15 min) x

Lower thresholds for bid sizes x

Risk hedging products to hedge

renewable energy volatility

x

Cross border capacity allocation for short-

term markets (i.e., some capacity being

reserved for intraday and balancing)

x

Introduction of longer-term transmission

rights ( > 3 years)

x

Regulatory measures to enable thermal,

electrical and chemical storage

x

Introduction of time-of-use retail prices x

Enshrine the right of consumers to

participate in the market through demand

response

x

The cross-border integration of liquid intraday and balancing markets, ensuring full participation of wind

generation, is a cornerstone of an efficient operation of the market with large shares of renewables.

Lack of harmonisation of gate closure times ranging from 75 min to 30 min before delivery (e.g. Germany, France

and Austria), constrains the possibility of trading wind power across borders. Harmonised intraday gate closure

times will allow wind power generators to adjust their balances by trading as close to real time as possible.

According to CACM guidelines, the intraday gate closure times “shall be at most one hour before the start of the

relevant market time unit”.

Given the intra hourly variability of wind energy, it would benefit from the introduction of more granular products

on intraday markets that are integrated across borders. EWEA therefore supports any initiative that would lead to

an alignment and shortening of trading intervals. This would also require a consistent imbalance settlement

period and calculation method. Such changes have the potential to significantly decrease balancing costs. In

addition, TSOs are highly interested in schedule nominations matching actual flows in order to ensure grid stability

and security of supply.

Regarding cross-border capacity allocation, EWEA deems necessary that all forms of reservation for balancing

purposes are subject to strict regulatory supervision, as this could reduce the integration of day-ahead and

intraday markets. All available cross border capacity should be allocated at all timeframes.

21

The Commission should also seek to improve participation of wind farms to balancing markets. In particular, it

should provide:

Standard detailed characteristics of the products that the balancing service providers will provide to the

balancing market: Minimum bid size applying in some Member States for Frequency Restoration Reserve

prevents some wind power plant operators from participating in the balancing market and the

qualification of these units as balancing service providers. This threshold should be lowered, and

aggregation of bids allowed.

Clear procurement rules: Capacity and energy should be procured in different products, revealing the real

cost of each of the services. Joint procurement limits participation of wind power producers because gate

closure time for capacity has long lead times that variable renewable plant owners are unable to meet.

With separate auctions immediately after the gate closure of the intraday markets variable energy

production from wind installations can deliver balancing energy at short notice. Balancing responsible

parties could offer balancing energy even if they did not have a capacity contract. Furthermore, there

should be a separation between upwards and downwards.

Validation procedures to demonstrate the delivery of balancing energy adapted to the characteristics of

wind power generation.

Importantly, compulsory grid support services requirements that are not remunerated should be minimised or

replaced by remuneration schemes. It is neither cost-efficient nor necessary to request services (including the

delivery of balancing energy) from all connected generators in most systems.

19. Currently, some exceptions from standard balancing responsibilities of generators exist for energy from

renewable sources. In view of increasingly mature renewable generation technologies and a growing role

of short-term markets, is time ready to in principle make all generation technologies subject to full

balancing responsibilities?

Yes, in principle everyone should have full balancing responsibility

No, we still need exemptions

EWEA believes that balancing responsibility for wind generators is possible and desirable in well-functioning

and integrated systems that allow them to compete on a level playing field with conventional generators.

Wind power generators are already balancing responsible in financial or legal terms in 14 Member States

where wind power has a share above 2% in annual generation. They are exposed to the same rules as

conventional generation12.

With current technology, wind power plants can provide ancillary services including balancing energy.

However, only a limited number of Member States currently have balancing markets and ancillary services

products whose rules take into account the intrinsic characteristics of wind generation. In most cases, wind

power is only partly allowed to participate in balancing markets, and often only in providing replacement

reserves. Overall, balancing market arrangements are mainly applicable for conventional power generators

only.

In the absence of a level playing field for renewable generators, exemptions therefore remain necessary.

Please specify: if exemptions remain necessary, if and in which case and why exemptions would still remain

necessary (e.g. small RES producers, non-mature technologies)?

12 EWEA, Balancing responsibilities and costs of wind power plants, September 2015

22

A one-size-fits-all solution is rarely the most cost-effective approach. Increased exposure to market risks applied in

mature markets should be limited to regions where physical, operational and regulatory preconditions are met.

Fundamental difference in power system characteristics (e.g. central vs. self-dispatch) may require different

approaches.

Moreover, exemptions should remain for existing plants. There should not be retroactive modification of their

operational responsibilities other than on a voluntary basis through incentives. It is not cost-effective to require

both market participation and balancing services capability from all generators. Small generation units should be

exempted as it would unnecessarily increase the administrative burden for them.

Therefore, all future considerations on balancing responsibilities by wind power generators need to take into

account:

the existence of suitable market rules allowing RES participation to the different balancing and ancillary

services markets;

the penetration level of wind energy (market maturity).

Market-specific boundary conditions under which balancing responsibility by wind power generators can be borne

include:

The full implementation of the EU target model:

o Day-ahead market coupling throughout the EU and implementation of the flow-based capacity

allocation method;

o Regional (e.g. Nord Pool) or at least national intraday and balancing markets are in place with

sufficient liquidity in terms of market participants and amount of transactions.

Balancing market arrangements providing for the participation of wind power generators (e.g. existence of

financial compensation, clear procurement rules and product specifications; see also question 18).

Market mechanisms that properly value the provision of ancillary or grid support services for all market

participants including wind power (e.g. Ireland).

A satisfactory level of market transparency and proper market monitoring:

o Balancing market arrangements and corresponding costs are to be assessed in a transparent

manner for all stakeholders, and the need for balancing services considered at the appropriate

level (system wide and cross-border versus localised needs). Moreover, any last resort decisions

such as curtailments must be well explained by the TSO and the calculation method of any

corresponding costs must be accessible and clear;

o An independent market monitoring entity must be set up (e.g. national regulatory authority) in

order to prevent and scrutinise any possible market distortive behaviours in the power sector

stemming from structural market inefficiencies such as market concentration.

Best use of sophisticated forecast methods and operational routines by TSOs. Wind power generation

forecasts is best suited take place 1 to 4 hours before real time and, ideally, be aggregated from several

sites. TSOs should improve their forecasting utilising state of the art methods during operations, while

increasing cross-border cooperation to reduce unexpected situations due to forecast errors.

Ensure a satisfactory level of grid reinforcements at transmission and distribution level.

Where these conditions are not provided, special temporary conditions should be granted to wind power

generators. This would guarantee a level playing field for these new market entrants that otherwise would be

disadvantaged compared to conventional generators.

23

20. Please assess the importance of stronger EU rules in the following areas to remove grid regulation and

infrastructure barriers for renewables electricity deployment:

Very

important

important Not very

important

Not

important

No

opinion

Treatment of curtailment, including

compensation for curtailment

x

Transparent and foreseeable grid

development, taking into account

renewable development and integrating

both TSO and DSO level and smart

technologies

x

Predictable transparent and non-

discriminatory connection procedure

x

Obligation/priority of connection for

renewables

x

Cost of grid access, including cost

structure

x

Legal position of renewable energy

developers to challenge grid access

decisions by TSOs

x

Transparency on local grid congestion

and/or market-based incentives to

invest in uncongested areas

x

Comments and other ideas, including whether there are any consideration concerning gas from renewable energy

sources, for instance expansion of gas infrastructure, publication of technical rules, please explain.

Important barriers faced by wind energy developers when it comes to grid connection are often related to an

absence of clear information from system operators on the available grid connection capacity, a lack of planning

for future grid extension and reinforcements and insufficient grid capacity. Regarding this latter point, guaranteed

or priority access is key to ensuring the development of the grid infrastructure necessary to effectively integrate

wind energy in a non-discriminatory way. This is especially the case in the countries without priority dispatch

provisions in their national law. There is also an unclear situation with regards to grid code requirements as they

are set out at European level (notably NC RfG), especially on the way they will be implemented at national level by

the TSOs and the DSOs.

Importantly, curtailment should not be seen as a way of solving network constraints or as a strategy for optimising

grid investments. This should result from an ex-ante agreement between the system operator and the generator to

reduce generation output in pre-defined situations (e.g. prevent grid congestion or when there is a threat to

system security). In this context, curtailment, be it voluntary or stemming from a restriction on operation, has to be

understood as a remunerated ancillary service providing downward reserve capacity or balancing energy. This

requires system operators to define procedures and compensation schemes in a transparent way. This principle of

compensation needs to be enshrined in the new Renewable Energy Directive. Such mechanisms13 would reduce

the volume risk for wind generators as new market entrants (consequently the cost of capital). They should be

13 As already applied in Croatia, Flanders, Germany, Greece, Romania, Sweden, and Ireland (until 2018).

24

separate revenue streams from those taken into consideration in the calculation of support mechanisms based

on energy output.

Overall, a careful balance between the benefits associated to carbon free production of electricity from low

marginal cost wind power and avoided investments in new grid infrastructure must be sought. A socio-economic

optimum in grid development planning should not only weigh the amount of curtailed energy against avoided grid

investment cost. It should also take into account other factors such as facilitating grid access to future power

generation units, safe system operation and overall system efficiency, social acceptance and enabling the

creation of the Internal Energy Market.

Regarding cost of grid access, see question 14.

Finally, the deployment of smart grid solutions is important to contain the overall system costs and facilitate the

integration of renewables in the long run, compared to the business-as-usual approach of grid reinforcement.

European legislation should therefore provide guidance to establish new regulatory approaches that incentivise

DSOs to deploy these solutions on a large scale, and implement revenue streams that will cover investment costs

related to ancillary services capabilities (e.g. reactive power).

21. Which obstacles, if any, would you see for the dispatching of energy from all generation sources including

renewables on the basis of merit order principles? Should there be any exemptions in some specific

cases?

X Yes, exemptions are necessary

No, merit order is sufficient

Priority dispatch for wind and other renewable should be maintained because the adequate safeguards are today

lacking to ensure that appropriate use of flexibility across the system, and to incentivise market players to

implement innovative practices.

The current lack of transparency in curtailment rules of wind generation (which represent an additional market

risk for wind energy generators) makes priority dispatch necessary to ensure the potential of this variable resource

is fully exploited. Priority dispatch makes the entire power generation fleet run in a more flexible way by forcing the

system operators to adopt more flexible system operation routines and to increase transparency in their

operational procedures. Combined with priority or guaranteed access, it ensures the optimal development of the

grid infrastructure necessary to effectively integrate wind and other renewables.

Future regulatory frameworks and power market design can consider increased exposure of wind generators to

market risk, including progressively phasing out priority dispatch or developing a more market-price responsive

mechanism in mature markets with high penetration levels of wind power. This would require at the same time the

removal of priority dispatch for conventional generation and all other forms of non-RES power generation14 in

order to have level playing field which can be further tested against the criteria listed in question 19.

Until these cumulative conditions are met, wind energy, as a variable renewable energy source, should continue to

benefit from priority/guaranteed access and/or priority dispatch.

Notwithstanding these criteria, priority dispatch should also be granted to ‘combined offshore grid solutions’

where two or more countries could be connected via offshore wind farms. This would more adequately reflect the

increased risks developers face in such novel approaches.

14 According to article 15(4) of the electricity directive, a Member State may give priority dispatch to power plants using indigenous primary

energy fuel sources, such as coal or peat (in a limit of 15% of the overall primary energy necessary to produce the electricity consumed. This

happens in Spain and Romania. CHP also benefits priority dispatch according to the energy efficiency directive.

25

22. Please asses the importance of stronger EU rules in the following areas to remove administrative barriers

to renewable energy deployment:

Very

important

important Not very

important

Not

important

No

opinion

Creation of a one stop shop at national

level to allow for more streamlined

permitting procedures

x

Online application for permits x

A defined maximum time-limit for

permitting procedures, and effective

consequences if deadline is missed

x

Harmonisation of national permitting

procedures

x

Special rules for facilitating small-scale

project permitting, including simple

notification

x

Pre-identified geographical areas for

renewable energy projects or other

measures to integrate renewable energy

in spatial and environmental planning

x

To what extent has the RED been successful in reducing unnecessary administrative barriers for renewable

energy projects in the Member States?

Administrative and permitting procedures are amongst the most important obstacles to the development of

renewables. They should be harmonized at national level and permitting policy should be coherent with the

planning of the territory and the grid developments. Simplified procedures should be adopted for the repowering

of the existing power plants – already integrated in the global social/economic and environmental system of a

territory.

Fair and shorter permitting and connection procedures would significantly reduce project development costs for

wind developers. The Renewable Energy Directive did not measurably help to reduce lead-times.

According to WindBarriers project conclusions, they face average lead times for administrative authorisation and

grid connection procedures of respectively 54.8 and 25.83 months. National authorities and network operators

should issue consent and connection of renewable generators within shorter and defined time-limits (the project

recommends 24 and 6 months respectively).

Another important barrier comes from the fact that onshore wind developers have to deal with nine different

authorities on average. As a prerequisite, Member States should streamline procedures and report improvements

as foreseen in the current Renewable Directive. In the long run, Member States should appoint a single permitting

authority that would be in charge of the coordinating the whole process, as it is the case for TEN-E / PCI projects.

(one stop shop solutions incorporating the tasks of all engaged authorities).

Others barriers faced by onshore wind developers relate to compliance with spatial planning, the number of

parties / authorities involved. For offshore wind developers, these are rather the administrative bodies’ lack of

26

experience, unclear environmental impact assessment processes, and difficult interaction with other users of the

sea.

EWEA’s priorities with regards to the streamlining of administrative procedures include:

More harmonized EU rules in a number of areas, including permitting procedures, spatial and

environmental planning and vocational and professional training. The introduction of measures to reduce

bureaucracy and increase transparency for example by promoting the use of electronic communication

during permitting procedure between investors and public authorities;

Repowering of RES projects should have streamlined authorization processes compared to greenfield

projects and the possibility of extension of licenses and connection rights. Dedicated competitive

mechanisms should be introduced to allocate support for re-powered wind farms;

Dedicated funds for professional conversion programs (training and job placement) towards green jobs

23. Please identify precise challenges with regard to grid regulation and infrastructure barriers in EU Member

States that you are aware of.

In addition to the barriers identified in question 20 and the potential solutions to address them, EWEA consider

the following issues to be of key important for the sustainable development of wind power in Europe:

- Transparent and predictable transposition of the Connection network codes into national legislation. In

particular the Network Code “Requirement for generators”, that is expected to enter into force in the Q1

of 2016 will have a significant impact on cost as well as on regulatory certainty. There are a number of

areas which are still open for Member States decision, such as test and compliance verification methods.

In fact 75% of the requirements within the network code are non-exhaustive, leaving a margin for

different interpretation. This creates uncertainty in the planning and design of wind farms that could lead

to diverse methodologies based on individual TSOs’ interpretation, therefore increasing grid access

barriers. In addition, an article in the NC RfG leaves the door open to national TSOs to extend the scope of

the requirements to existing generators under certain economic justification and under certain

conditions, posing a risk of increased investment and operational costs for existing investments.

These requirements need to be specified within 2 years after NC RfG comes into effect in national

regulation. Industry will then have 1 year more for adoption of the requirements into new equipment and

power plants specifications. The next 3 years will be crucial to determine whether the national

frameworks for grid connection and operation are fit for technology and economic competitiveness of the

wind power technology. The way national TSOs and regulators handle this process, and they way they

involve industry will be decisive to reduce regulatory uncertainty and to keep technology costs as

competitive as possible.

- Acceleration on the development of a Pan-European electricity network. The recently completed EC

funded project e-highway project showed that the expected 2030 network is not yet fit for the EU's 2050

energy and climate goals. The project has revealed that benefits of more transmission capacity will

outweigh the costs, especially for those scenarios with large penetration of renewable energy source. One

of the main challenges lays on the ability to allocate cost among member states for projects of cross-

border significance. An EU-wide transparent and clear methodology for cross border cost allocation

involving multiple countries is needed. Another important challenge is the lack of a common vision and a

stable investment framework for renewables. Long-term renewable targets and a strategically

coordinated grid design and planning would ensure a smooth development of the energy system in a cost-

effective fashion.

27

24. How would you rate the administrative burden and cost of compliance with the RED for national, regional

and local authorities?

No opinion.

Very important Important Not very

important

Not important No opinion

Administrative

burden

Cost of

compliance

25. Please rate the importance of stronger EU rules in the following areas to remove barriers relating to

renewable energy training and certification:

Very

important

important Not very

important

Not

important

No

opinion

Incentives for installers to participate in

certification/qualification schemes

Increased control and quality assurance

from public authorities

Understanding of the benefits and

potential of renewable technologies by

installers

Mutual recognition of certificates

between different Member States

26. How can public acceptance towards renewable energy projects and related grid development be

improved?

Social acceptance of wind energy in the EU is generally high with 89% of Europeans being favourable to wind

projects15. However, local communities sometimes perceive wind farms, their overhead lines and - grid

infrastructure, as intrusive and of limited value to the community.

Enhanced public engagement

The need for a lean planning process and well-defined roles for the bodies involved in planning is crucial. National

planning and permitting regulations and strategies are essential to understand the level of public participation

and information during wind farm development. Citizens should be engaged in a transparent way, by fully

respecting the principles of openness, inclusiveness, responsiveness, accountability and flexibility.

EWEA is currently actively working on social acceptance in the framework of WISE Power, an EU-funded project

aiming at improving local engagement and support for wind turbines while enhancing local community

15 Eurobarometer survey. 2011

28

participation in the planning and implementation of wind power. The project has strongly focused on local

participation and alternative financing measures as methods to enhance social engagement. The measures

suggested by the project support stakeholders to design, build, implement and deliver effective and meaningful

social engagement strategies in relation to onshore wind farms.

Diversification of alternative financing to support wind power development

Innovative financing provides an effective strategy to foster public acceptance for wind projects. Several models of

alternative financing are used in Europe to develop wind farms. These models aim at securing financing for the

projects, thus making the projects more bankable, WISE Power looked into the various types of so- called

innovative financing and underlined five main types of models: donation based crowdfunding, private partnership

including a citizen cooperative, public private partnership including a public entity, underwriter fund constituted

with public bodies and underwriter fund constituted with cooperatives.

Defining one single innovative financing mechanism that contributes to enhancing social acceptance of wind

energy, improves bankability of projects, insures successful implementation of wind farms and offers attractive

financial conditions is a complex exercise. The challenge comes from the cultural, economic and institutional

aspects specific to every project. Nevertheless, the private partnerships which include at least one citizen

cooperative offer a good compromise between successful implementation, bankability of the project and social

acceptance, this is especially true in the case of the mature wind power markets (e.g. Denmark, UK, Scotland)

where the regulatory frameworks in place are supporting these initiatives.

Lack of public support will often result in delays to the selection of adequate sites and development of electricity

infrastructure projects, which also stops communities from sharing in the benefits. Promoting acceptance needs

to be taken on board by all stakeholders and have a strong political backing. Shared benefits from the

construction of onshore wind farms can also help overcome resistance. Boosting local economy, creating local

employment, providing revenues from the lease of land, sponsorship of educational and cultural events,

construction of associated infrastructure are examples of community benefits from wind power development,

which depend on the type of project, region, country, regulatory frameworks and other ad hoc issues.

Increasing the renewable energy use in the transport sector

28. To what extent has the RED been successful in addressing the following EU transport policy objectives?

Very

important

important Not very

important

Not

important

No

opinion

Contribute towards the EU's

decarbonisation objectives

Reduce dependency on oil imports

Increase diversification of transport

fuels

Increase energy recovery from wastes

Reduce air pollution, particularly in

urban areas

Strengthen the EU industry and

economy competitiveness

Stimulate development and growth of

innovative technologies

Reduce production costs of renewable

fuels by lowering the level of investment

29

risk

Facilitate fuel cost reduction by

integration of the EU market for

renewable fuels

29. Please name the most important barriers hampering the development of sustainable renewable fuels

and renewable electricity in transport.

30. Please rate the most effective means of promoting the consumption of sustainable renewable fuels in

the EU transport sector and increasing the uptake of electric vehicles:

Very

important

important Not very

important

Not

important

No

opinion

Increased use of certain market players'

obligations at Member State level

More harmonised promotion measures

at Member States level

The introduction of certain market

players' obligations at the EU level

Targeted financial support for

deployment of innovative low-carbon

technologies (in particular to the heavy

duty transport and aviation industry)

Increased access to energy system

services (such as balancing and voltage

and frequency support when using

electric vehicles)

Increased access to alternative fuel

infrastructure (such as electric vehicle

charging points)